On the evidence, "it's open to the Commissioner to find that Bankwest may have engaged in conduct that fell below community standards and expectations in the following ways," Rowena Orr, counsel assisting the Hayne royal commission began at the final hearing in Darwin on Friday."First, Bankwest failed to take adequate care in preparing … internal valuations," Orr said. "Second, Bankwest failed to have adequate systems in place to detect that [an] internal valuation was incorrect. "Third, Bankwest's processes were lax in several significant respects as demonstrated by misstated valuations, undated guarantees, and guarantees that were signed before letters of offer."In the specific instance of dealing with the Ruddys, cattle farmers,  "when formulating its strategy for dealing with the Ruddys after the receipt of the May 2013 valuations, Bankwest determined that the appropriate course was to declare the May 2013 letters of offer null and void, forbear the Ruddys' loan to value ratio breach, and issue new letters of variation," Orr said. "In issuing the new letters of variation, Bankwest appears to have been motivated by a concern to increase the Ruddys' overdraft sufficiently so that Bankwest could charge the external valuation fees to the account. "Fifth, as [the bank] accepted, Bankwest did not deal with FOS in a full and frank way in relation to the Ruddys dispute. Sixth, the guarantee provided by the Ruddys' son changed multiple times during the life of the facility. "Bankwest, Orr said, "have characterised the changes as being 'troubling', and accepted that there was no explanation as to why the guarantee wasn't maintained with the facilities. "On the evidence, it's open to the Commissioner to find that there were a number of causes of the misconduct which are attributable to Bankwest's culture and governance practices, as well as to its remuneration practices and to inadequate internal systems. "It's open to the Commissioner to find that a significant cause of the misconduct was Bankwest's remuneration and incentive scheme. "The evidence establishes that at the time Bankwest offered the facilities to the Ruddys, 60 per cent of its KPIs for employees like the bank manager were weighted towards profitable growth. Half of that was allocated to asset sales targets."